EFTA00067398

Case 9:08-cv-80119-KAM 
Document 65-4 
Entered on FLSD Docket 03/25/2009 
Page 1 of 37 
UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF FLORIDA 
CASE NO.: 08-CV-80119-MARRA-JOHNSON 
JANE DOE NO. 2, 
Plaintiff, 
v. 
JEFFREY EPSTEIN, 
Defendant. 
DEFENDANT EPSTEIN'S RESPONSE & OBJECTIONS 
TO PLAINTIFF'S AMENDED FIRST SET OF INTERROGATORIES 
Defendant, JEFFREY EPSTEIN, by and through his undersigned attorneys, 
serves his responses and objections to Plaintiffs December 9, 2008 Amended First Set 
Of Interrogatories To Defendant Jeffrey Epstein, attached hereto. 
Certificate of Service 
I HEREBY CERTIFY that a true copy of the foregoing has been sent by fax and 
U.S. Mail to the following addressees this  26th 
 day of January, 2009: 
Adam D. Horowitz, Esq. 
Jeffrey Marc Herman, Esq. 
Stuart S. Mermelstein Es 
ounse • r 
aintiff Jane Doe #2 
Jack Alan Goldberger 
Atterbury Goldberger & Weiss. P.A. 
Co-Counsel for Defendant Jeffrey Epstein 
Corn P
/I(EXHIBIT '02 
EFTA00067398

Case 9:08-cv-80119-KAM 
Document 65-4 
Entered on FLSD Docket 03/25/2009 
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Jane Doe No. 2 v. Epstein 
Page 2 
Respectfully su 
itted, 
By: 
ROBERT 
RITTON, JR., ESQ. 
Florida Ba 
SQ. 
, LUTTIER & COLEMAN 
(Co-Counsel for Defendant Jeffrey Epstein) 
EFTA00067399

Case 9:08-cv-80119-KAM 
Document 65-4 
Entered on FLSD Docket 03/25/2009 
Page 3 of 37 
Jane Doe No. 2 v. Epstein 
Page 3 
DEFENDANT JEFFREY EPSTEIN'S ANSWERS AND OBJECTIONS TO 
PLAINTIFF'S AMENDED FIRST SET OF INTERROGATORIES 
Interrogatory No. 1. 
Identify all employees who performed work of services inside 
the Palm Beach Residence. 
Answer: 
Defendant is asserting specific legal objections to the interrogatories as 
well as his U.S. constitutional privileges. I intend to respond to all relevant questions 
regarding this lawsuit, however, my attorneys have counseled me that I cannot provide 
answers to any questions relevant to this lawsuit and I must accept this advice or risk 
losing my Sixth Amendment right to effective representation. Accordingly, I assert my 
federal constitutional rights under the Fifth, Sixth, and Fourteenth Amendments as 
guaranteed by the United States Constitution. Drawing an adverse inference under 
these circumstances would unconstitutionally burden my exercise of my constitutional 
rights, would be unreasonable, and would therefore violate the Constitution. In addition 
to and without waiving his constitutional privileges, Defendant objects as the 
interrogatory is overbroad and seeks information that is neither relevant to the subject 
matter of the pending action nor does it appear reasonably calculated to lead to the 
discovery of admissible evidence. Plaintiffs Complaint alleges a time period of "in or 
about 2004-2005." Plaintiffs interrogatory seeks information for a time period from 
January 1, 2003 until present. Also, see "Employee" as defined in paragraph g of 
Plaintiffs interrogatories. 
Interrogatory No. 2. 
Identify all Employees not identified in response to 
interrogatory no. 1 who at any time came to Defendant's Palm Beach Residence. 
Answer: 
Defendant is asserting specific legal objections to the interrogatories as 
well as his U.S. constitutional privileges. I intend to respond to all relevant questions 
regarding this lawsuit, however, my attorneys have counseled me that I cannot provide 
answers to any questions relevant to this lawsuit and I must accept this advice or risk 
losing my Sixth Amendment right to effective representation. Accordingly, I assert my 
federal constitutional rights under the Fifth, Sixth, and Fourteenth Amendments as 
guaranteed by the United States Constitution. Drawing an adverse inference under 
these circumstances would unconstitutionally burden my exercise of my constitutional 
rights, would be unreasonable, and would therefore violate the Constitution. In addition 
to and without waiving his constitutional privileges, Defendant objects as the 
interrogatory is overbroad and seeks information that is neither relevant to the subject 
matter of the pending action nor does it appear reasonably calculated to lead to the 
discovery of admissible evidence. Plaintiffs Complaint alleges a time period of "in or 
about 2004-2005." Plaintiffs interrogatory seeks information for "all Employees" "who at 
any time" came to the residence. Also, see "Employee" as defined in paragraph g of 
Plaintiffs interrogatories. 
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Document 65-4 
Entered on FLSD Docket 03/25/2009 
Page 4 of 37 
Jane Doe No. 2 v. Epstein 
Page 4 
Interrogatory No. 3. 
Identify all persons who came to the Palm Beach Residence 
and who gave a massage or were asked to give a massage to Defendant. 
Answer: 
Defendant is asserting specific legal objections to the interrogatories as 
well as his U.S. constitutional privileges. I intend to respond to all relevant questions 
regarding this lawsuit, however, my attorneys have counseled me that I cannot provide 
answers to any questions relevant to this lawsuit and I must accept this advice or risk 
losing my Sixth Amendment right to effective representation. Accordingly, I assert my 
federal constitutional rights under the Fifth, Sixth, and Fourteenth Amendments as 
guaranteed by the United States Constitution. Drawing an adverse inference under 
these circumstances would unconstitutionally burden my exercise of my constitutional 
rights, would be unreasonable, and would therefore violate the Constitution. In addition 
to and without waiving his constitutional privileges, Defendant objects as the 
interrogatory is overbroad and seeks information that is neither relevant to the subject 
matter of the pending action nor does it appear reasonably calculated to lead to the 
discovery of admissible evidence. Plaintiffs Complaint alleges a time period of "in or 
about 2004-2005." 
Interrogatory No. 4. 
Identify all persons who came to the New York Residence 
and who gave a massage or were asked to give a massage to Defendant. 
Answer: 
Defendant is asserting specific legal objections to the interrogatories as 
well as his U.S. constitutional privileges. I intend to respond to all relevant questions 
regarding this lawsuit, however, my attorneys have counseled me that I cannot provide 
answers to any questions relevant to this lawsuit and I must accept this advice or risk 
losing my Sixth Amendment right to effective representation. Accordingly, I assert my 
federal constitutional rights under the Fifth, Sixth, and Fourteenth Amendments as 
guaranteed by the United States Constitution. Drawing an adverse inference under 
these circumstances would unconstitutionally burden my exercise of my constitutional 
rights, would be unreasonable, and would therefore violate the Constitution. In addition 
to and without waiving his constitutional privileges, Defendant objects as the 
interrogatory is overbroad and seeks information that is neither relevant to the subject 
matter of the pending action nor does it appear reasonably calculated to lead to the 
discovery of admissible evidence. Plaintiffs Complaint alleges a time period of "in or 
about 2004-2005." 
Interrogatory No. 5. 
Identify all persons who came to the New Mexico Residence 
and who gave a massage or were asked to give a massage to Defendant. 
Answer: 
Defendant is asserting specific legal objections to the interrogatories as 
well as his U.S. constitutional privileges. I intend to respond to all relevant questions 
regarding this lawsuit, however, my attorneys have counseled me that I cannot provide 
answers to any questions relevant to this lawsuit and I must accept this advice or risk 
losing my Sixth Amendment right to effective representation. Accordingly, I assert my 
EFTA00067401

Case 9:08-cv-80119-KAM 
Document 65-4 
Entered on FLSD Docket 03/25/2009 
Page 5 of 37 
Jane Doe No. 2 v. Epstein 
Page 5 
federal constitutional rights under the Fifth, Sixth, and Fourteenth Amendments as 
guaranteed by the United States Constitution. Drawing an adverse inference under 
these circumstances would unconstitutionally burden my exercise of my constitutional 
rights, would be unreasonable, and would therefore violate the Constitution. In addition 
to and without waiving his constitutional privileges, Defendant objects as the 
interrogatory is overbroad and seeks information that is neither relevant to the subject 
matter of the pending action nor does it appear reasonably calculated to lead to the 
discovery of admissible evidence. Plaintiff's Complaint alleges a time period of "in or 
about 2004-2005." 
Interrogatory No. 6. 
Identify all persons who came to the St. Thomas Residence 
and who gave a massage or were asked to give a massage to Defendant. 
Answer: 
Defendant is asserting specific legal objections to the interrogatories as 
well as his U.S. constitutional privileges. I intend to respond to all relevant questions 
regarding this lawsuit, however, my attorneys have counseled me that I cannot provide 
answers to any questions relevant to this lawsuit and I must accept this advice or risk 
losing my Sixth Amendment right to effective representation. Accordingly, I assert my 
federal constitutional rights under the Fifth, Sixth, and Fourteenth Amendments as 
guaranteed by the United States Constitution. Drawing an adverse inference under 
these circumstances would unconstitutionally burden my exercise of my constitutional 
rights, would be unreasonable, and would therefore violate the Constitution. In addition 
to and without waiving his constitutional privileges, Defendant objects as the 
interrogatory is overbroad and seeks information that is neither relevant to the subject 
matter of the pending action nor does it appear reasonably calculated to lead to the 
discovery of admissible evidence. Plaintiffs Complaint alleges a time period of "in or 
about 2004-2005." 
Interrogatory No. 7. 
List all the time periods during which Jeffrey Epstein was 
present in the State of Florida, including for each the date he arrive and the date he 
departed. 
Answer: 
Defendant is asserting specific legal objections to the interrogatories as 
well as his U.S. constitutional privileges. I intend to respond to all relevant questions 
regarding this lawsuit, however, my attorneys have counseled me that I cannot provide 
answers to any questions relevant to this lawsuit and I must accept this advice or risk 
losing my Sixth Amendment right to effective representation. Accordingly, I assert my 
federal constitutional rights under the Fifth, Sixth, and Fourteenth Amendments as 
guaranteed by the United States Constitution. Drawing an adverse inference under 
these circumstances would unconstitutionally burden my exercise of my constitutional 
rights, would be unreasonable, and would therefore violate the Constitution. In addition 
to and without waiving his constitutional privileges, Defendant also objects as the 
interrogatory is overbroad and seeks information that is neither relevant to the subject 
matter of the pending action nor does it appear reasonably calculated to lead to the 
EFTA00067402

Cise 9:08-cv-80119-KAM 
Document 65-4 
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Jane Doe No. 2 v. Epstein 
Page 6 
discovery of admissible evidence. Plaintiffs Complaint alleges a time period of "in or 
about 2004-2005." Plaintiffs interrogatory seeks information for a time period from 
January 1, 2003 until present. 
Interrogatory No. 8. 
Identify all of Jeffrey Epstein health care providers in the 
past (10) ten years, including without limitation, psychologists, psychiatrists, mental 
health counselors, physicians, hospitals and treatment facilities. 
Answer: 
Defendant is asserting specific legal objections to the interrogatories as 
well as his U.S. constitutional privileges. I intend to respond to all relevant questions 
regarding this lawsuit, however, my attorneys have counseled me that I cannot provide 
answers to any questions relevant to this lawsuit and I must accept this advice or risk 
losing my Sixth Amendment right to effective representation. Accordingly, I assert my 
federal constitutional rights under the Fifth, Sixth, and Fourteenth Amendments as 
guaranteed by the United States Constitution. Drawing an adverse inference under 
these circumstances would unconstitutionally burden my exercise of my constitutional 
rights, would be unreasonable, and would therefore violate the Constitution. In addition 
to and without waiving his constitutional privileges, Defendant also objects as the 
interrogatory is overbroad and seeks information that is neither relevant to the subject 
matter of the pending action nor does it appear reasonably calculated to lead to the 
discovery of admissible evidence. In addition, such information is privileged pursuant to 
Rule 501, Fed. Evid., and §90.503, FIa.Evid. Code. In addition, such information is 
protected by the provisions of the Health Insurance Portability and Accountability Act 
(HI PAA). 
Interrogatory No. 9. 
List all items in Jeffrey Epstein's possession in Palm Beach, 
Florida, at any time during the period of these interrogatories, which were used or 
intended to be used as sexual aids, sex toys, massage aids, and/or vibrators, and for 
each, list the manufacturer, model number (if applicable), and its present location. 
Answer: 
Defendant is asserting specific legal objections to the interrogatories as 
well as his U.S. constitutional privileges. I intend to respond to all relevant questions 
regarding this lawsuit, however, my attorneys have counseled me that I cannot provide 
answers to any questions relevant to this lawsuit and I must accept this advice or risk 
losing my Sixth Amendment right to effective representation. Accordingly, I assert my 
federal constitutional rights under the Fifth, Sixth, and Fourteenth Amendments as 
guaranteed by the United States Constitution. Drawing an adverse inference under 
these circumstances would unconstitutionally burden my exercise of my constitutional 
rights, would be unreasonable, and would therefore violate the Constitution. In addition 
to and without waiving his constitutional privileges, Defendant also objects as the 
interrogatory is overbroad and seeks information that is neither relevant to the subject 
matter of the pending action nor does it appear reasonably calculated to lead to the 
discovery of admissible evidence. Plaintiffs Amended Complaint alleges a time period 
of "in or about 2004 — 2005," while Plaintiffs interrogatory seeks information from 
EFTA00067403

Case 9:08-cv-80119-KAM 
Document 65-4 
Entered on FLSD Docket 03/25/2009 
Page 7 of 37 
Jane Doe No. 2 v. Epstein 
Page 7 
January 1, 2003, until present. Further, the request is meant to embarrass and harass 
the Defendant. 
Interrogatory No. 10. 
Identify all persons who provide transportation services to 
Jeffrey Epstein, whether as employees or independent contractors, including without 
limitation, chauffeurs and aircraft crew. 
Answer: 
Defendant is asserting specific legal objections to the interrogatories as 
well as his U.S. constitutional privileges. I intend to respond to all relevant questions 
regarding this lawsuit, however, my attorneys have counseled me that I cannot provide 
answers to any questions relevant to this lawsuit and I must accept this advice or risk 
losing my Sixth Amendment right to effective representation. Accordingly, I assert my 
federal constitutional rights under the Fifth, Sixth, and Fourteenth Amendments as 
guaranteed by the United States Constitution. Drawing an adverse inference under 
these circumstances would unconstitutionally burden my exercise of my constitutional 
rights, would be unreasonable, and would therefore violate the Constitution. In addition 
to and without waiving his constitutional privileges, Defendant also objects as the 
interrogatory is overbroad and seeks information that is neither relevant to the subject 
matter of the pending action nor does it appear reasonably calculated to lead to the 
discovery of admissible evidence. Plaintiff places no time limitation. 
Interrogatory No. 11. 
Identify all telephone numbers used by Epstein, including 
cellular phones and land lines in any of his residences, by stating the complete 
telephone number and the name of the service provider. 
Answer: 
Defendant is asserting specific legal objections to the interrogatories as 
well as his U.S. constitutional privileges. I intend to respond to all relevant questions 
regarding this lawsuit, however, my attorneys have counseled me that I cannot provide 
answers to any questions relevant to this lawsuit and I must accept this advice or risk 
losing my Sixth Amendment right to effective representation. Accordingly, I assert my 
federal constitutional rights under the Fifth, Sixth, and Fourteenth Amendments as 
guaranteed by the United States Constitution. Drawing an adverse inference under 
these circumstances would unconstitutionally burden my exercise of my constitutional 
rights, would be unreasonable, and would therefore violate the Constitution. In addition 
to and without waiving his constitutional privileges, Defendant also objects as the 
interrogatory is overbroad and seeks information that is neither relevant to the subject 
matter of the pending action nor does it appear reasonably calculated to lead to the 
discovery of admissible evidence. Plaintiffs allegations claim a time period of "in or 
about 2004-2005" and involve Defendant's Palm Beach residence. 
Interrogatory No. 12. 
Identify all telephone numbers of employees of Epstein, 
used in the course or scope of their employment, including cellular phones and land 
lines in any of his residences, by stating the complete telephone number and the name 
of the service provider. 
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Case 9:08-cv-80119-KAM 
Document 65-4 
Entered on FLSD Docket 03/25/2009 
Page 8 of 37 
Jane Doe No. 2 v. Epstein 
Page 8 
Answer: 
Defendant is asserting specific legal objections to the interrogatories as 
well as his U.S. constitutional privileges. I intend to respond to all relevant questions 
regarding this lawsuit, however, my attorneys have counseled me that I cannot provide 
answers to any questions relevant to this lawsuit and I must accept this advice or risk 
losing my Sixth Amendment right to effective representation. Accordingly, I assert my 
federal constitutional rights under the Fifth, Sixth, and Fourteenth Amendments as 
guaranteed by the United States Constitution. Drawing an adverse inference under 
these circumstances would unconstitutionally burden my exercise of my constitutional 
rights, would be unreasonable, and would therefore violate the Constitution. In addition 
to and without waiving his constitutional privileges, Defendant objects as the 
interrogatory is overbroad and seeks information that is neither relevant to the subject 
matter of the pending action nor does it appear reasonably calculated to lead to the 
discovery of admissible evidence. Plaintiffs allegations claim a time period of min or 
about 2004-2005" and involve Defendant's Palm Beach residence. 
Interrogatory No. 13. 
List the names and addresses of all persons who are 
believed or known by your, your agents, or your attorneys to have any knowledge 
concerning any of the issues in this lawsuit; and specify the subject matter about which 
the witness has knowledge. 
Answer: 
Defendant is asserting specific legal objections to the interrogatories as 
well as his U.S. constitutional privileges. I intend to respond to all relevant questions 
regarding this lawsuit, however, my attorneys have counseled me that I cannot provide 
answers to any questions relevant to this lawsuit and I must accept this advice or risk 
losing my Sixth Amendment right to effective representation. Accordingly, I assert my 
federal constitutional rights under the Fifth, Sixth, and Fourteenth Amendments as 
guaranteed by the United States Constitution. Drawing an adverse inference under 
these circumstances would unconstitutionally burden my exercise of my constitutional 
rights, would be unreasonable, and would therefore violate the Constitution. In addition 
to and without waiving his constitutional privileges, the interrogatory seeks information 
that is attorney-client and work product privileged as it seeks information known by 
Defendant's attorneys. 
The interrogatory is so overbroad that Defendant cannot 
reasonably form a response, including the raising of additional privileges which may 
apply. Without waiving any objection, see Rule 26 disclosures made by Defendant's 
counsel in this case. 
Interrogatory No. 14. 
State the name and address of every person known to you, 
your agents, or your attorneys who has knowledge about, possession, or custody, or 
control of, any model, plat, map, drawing, motion picture, videotape or photograph 
pertaining to any fact or issue involved in this controversy; and describe as to each, 
what item such person has, the name and address of the person who took or prepared 
it, and the date it was taken or prepared. 
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Document 65-4 
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Page 9 of 37 
Jane Doe No. 2 v. Epstein 
Page 9 
Answer: 
Defendant is asserting specific legal objections to the interrogatories as 
well as his U.S. constitutional privileges. I intend to respond to all relevant questions 
regarding this lawsuit, however, my attorneys have counseled me that I cannot provide 
answers to any questions relevant to this lawsuit and I must accept this advice or risk 
losing my Sixth Amendment right to effective representation. Accordingly, I assert my 
federal constitutional rights under the Fifth, Sixth, and Fourteenth Amendments as 
guaranteed by the United States Constitution. Drawing an adverse inference under 
these circumstances would unconstitutionally burden my exercise of my constitutional 
rights, would be unreasonable, and would therefore violate the Constitution. In addition 
to and without waiving his constitutional privileges, the interrogatory seeks information 
that is attorney-client and work product privileged as it seeks information known by 
Defendant's attorneys. 
Interrogatory No. 15. 
Identify all persons who have made a claim, complaint, 
demand or threat against you relating to alleged sexual abuse or misconduct on a 
minor, and for each provide the following information: 
a. The person's full name, last known address and telephone number; 
b. The person's attorney, if represented; 
c. The date of the alleged incident(s); 
d. If a civil case has been filed by or on behalf of the person, the case number 
and identifying information. 
Answer: 
Defendant is asserting specific legal objections to the interrogatories as 
well as his U.S. constitutional privileges. I intend to respond to all relevant questions 
regarding this lawsuit, however, my attorneys have counseled me that I cannot provide 
answers to any questions relevant to this lawsuit and I must accept this advice or risk 
losing my Sixth Amendment right to effective representation. Accordingly, I assert my 
federal constitutional rights under the Fifth, Sixth, and Fourteenth Amendments as 
guaranteed by the United States Constitution. Drawing an adverse inference under 
these circumstances would unconstitutionally burden my exercise of my constitutional 
rights, would be unreasonable, and would therefore violate the Constitution. In addition 
to and without waiving his constitutional privileges and without waiving such objection, 
with regard to subparagraph (d), Defendant's counsel states that such information is 
public record and equally attainable by Plaintiff. 
Interrogatory No. 16. 
State the facts upon which you intend to rely for each denial 
of a pleading allegation and for each affirmative defense you intend to make in these 
cases. 
Answer: 
Defendant is asserting specific legal objections to the interrogatories as 
well as his U.S. constitutional privileges. I intend to respond to all relevant questions 
regarding this lawsuit, however, my attorneys have counseled me that I cannot provide 
answers to any questions relevant to this lawsuit and I must accept this advice or risk 
EFTA00067406

Case 9:08-cv-80119-KAM 
Document 65-4 
Entered on FLSD Docket 03/25/2009 
Page 10 of 37 
Jane Doe No. 2 v. Epstein 
Page 10 
losing my Sixth Amendment right to effective representation. Accordingly, I assert my 
federal constitutional rights under the Fifth, Sixth, and Fourteenth Amendments as 
guaranteed by the United States Constitution. Drawing an adverse inference under 
these circumstances would unconstitutionally burden my exercise of my constitutional 
rights, would be unreasonable, and would therefore violate the Constitution. In addition 
to and without waiving his constitutional privileges, no answer to the Amended 
Complaint has been filed by defense counsel in this case; however, Defendant does not 
intend to waive his constitutional privilege against self-incrimination. Defendant further 
objects in that Plaintiffs interrogatory attempts to obtain discovery in other cases filed 
by her undersigned counsel. 
Interrogatory No. 17. 
Identify all witnesses from whom you have obtained or 
requested a written, transcribed or recorded statement relating to any issue in these 
cases, and for each, in addition to the witness's identifying information, state the date of 
the statement and identify the person taking the statement. 
Answer: Defendant is asserting specific legal objections to the interrogatories as well 
as his U.S. constitutional privileges. I intend to respond to all relevant questions 
regarding this lawsuit, however, my attorneys have counseled me that I cannot provide 
answers to any questions relevant to this lawsuit and I must accept this advice or risk 
losing my Sixth Amendment right to effective representation. Accordingly, I assert my 
federal constitutional rights under the Fifth, Sixth, and Fourteenth Amendments as 
guaranteed by the United States Constitution. Drawing an adverse inference under 
these circumstances would unconstitutionally burden my exercise of my constitutional 
rights, would be unreasonable, and would therefore violate the Constitution. In addition 
to and without waiving his constitutional privileges, Defendant objects to this 
interrogatory in that it seeks information that is attorney-client and work product 
privileged. In addition, the request is overbroad in that it seeks information "relating to 
any issue." 
STATE OF Flor.‘ 
COUNTY OF 9c,\. 
Ckery 
) 
I hereby certify that on this day, before me, an officer duly authorized to administer oaths 
and take acknowledgments, personally appeared  
e_sccrr..z.i 
 , known to 
me to be the person described in and who executed the foregoing Interrogatories who 
EFTA00067407

. 
Case 9:08-cv-80119-KAM 
Document 65-4 
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Jane Doe No. 2 v. Epstein 
Page 11 
acknowledged before me that he/she executed the same, that I relied upon the following form of 
identification of the above-named person: personally known/identification and that an oath 
was/was not taken. 
WITNESS my hand and official seal in the County and State last aforesaid this 
2.6*
day of  \ar‘..acar..‘  
 2009. 
(SEAL) 
NOTARY PUBLIC-STATE OF FLORIDA 
(* 
?trial 
Commission 
Expires: D 
BONDED THRU Amur= BONDING CO, Bic 
• 
••••• 
PRelatrvIE:  
cs1/4krxr..en.. Mrktit 
Notary Public/State of Florida 
Commission #: 
My Commission Expires: 
EFTA00067408

Case 9:08-cv-80119-KAM 
Document 65-4 
Entered on FLSD Docket 03/25/2009 
Page 12 of 37 
UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF FLORIDA 
CASE NO.: 08-CV-80119-MARRA-JOHNSON 
JANE DOE NO. 2, 
Plaintiff, 
v. 
JEFFREY EPSTEIN, 
Defendant. 
DEFENDANT JEFFREY EPSTEIN'S RESPONSE & OBJECTIONS TO 
SECOND REQUEST FOR PRODUCTION, dated December 19, 2008 
Defendant, JEFFREY EPSTEIN, by and through his undersigned 
attorneys, serves his responses and objections to the Request to Produce, dated 
December 19, 2008 and states: 
Request No. 1. 
All policies of insurance, including the declarations 
page and all binders, amendments, and endorsements, covering Defendant's 
residence at 358 El Brillo Way, Palm Beach, FL 33480. 
Response: Objection, overly broad, not relevant and material and not 
calculated to lead to the discovery of admissible evidence. Plaintiff alleged 
claims occurred during a specific time period in 2004 - 2005, yet to be 
specifically identified. Yet, no time period whatsoever is set forth in the Request 
for Production. Additionally, Defendant objects in that the policies contain value 
and/or asset information which is not relevant, material nor calculated to lead to 
the discovery of admissible evidence at this point in time; said information is both 
private and confidential. 
ecier*lis 
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Jane Doe No. 2 v. Epstein 
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Certificate of Service 
WE HEREBY CERTIFY that a true copy of the foregoing has been sent 
via U.S. Mail and facsimile to the following addressees this  26th 
 day of 
January 2009. 
Adam D. Horowitz, Esq. 
Jeffrey Marc Herman, Esq.
Stuart S. M rmelstein Es 
Counsel for Plaintiff Jane Doe #2 
Jack Alan Goldberger 
A 
o- ounse or Defendant Jeffrey 
Epstein 
Respectfull sub 
ed 
By: 
ROBER 
Florida Ba 
MICHAEL J. PIKE ESQ. 
Florida Bar 
BURMAN, CRITTON, LUTTIER & 
COLEMAN 
(Co-counsel for Defendant Jeffrey Epstein) 
EFTA00067410

Case 9:08-cv-80119-KAM 
Document 65-4 
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Page 14 of 37 
UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF FLORIDA 
CASE NO.: 08-CV-80119-MARRA-JOHNSON 
JANE DOE NO. 2, 
Plaintiff, 
v. 
JEFFREY EPSTEIN, 
Defendant. 
DEFENDANT JEFFREY EPSTEIN'S RESPONSE & OBJECTIONS 
TO PLAINTIFF'S AMENDED FIRST REQUEST FOR PRODUCTION 
Defendant, JEFFREY EPSTEIN, by and through his undersigned counsel, 
serves his responses and objections to Plaintiff's Amended First Request For 
Production To Defendant, dated December 9, 2008. 
Request No. 1. 
The list provided to you by the U.S. Attorney of individuals 
whom the U.S. Attorney was prepared to name in an Indictment as victims of an 
offense by Mr. Epstein enumerated in 18 U.S.C. §2255. 
Response: 
Defendant is asserting specific legal objections to the production 
request as well as his U.S. constitutional privileges. I intend to produce all 
relevant documents regarding this lawsuit, however, my attorneys have 
counseled me that at the present time I cannot select, authenticate, and produce 
documents relevant to this lawsuit and I must accept this advice or risk losing my 
Sixth Amendment right to effective representation. Accordingly, I assert my 
federal constitutional rights under the Fifth, Sixth, and Fourteenth Amendments 
as guaranteed by the United States Constitution. Drawing an adverse inference 
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Jane Doe No. 2 v. Epstein 
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under these circumstances would unconstitutionally burden my exercise of my 
constitutional rights, would be unreasonable, and would therefore violate the 
Constitution. In addition to and without waiving his constitutional privileges, the 
information sought is privileged and confidential, and inadmissible pursuant to 
the terms of the deferred prosecution agreement, Fed. Rule of Evidence 410 and 
408, and §90.410, Fla. Stat. Further, the request is overly broad, work product, 
attorney-client privileged, and confidential. 
In addition, the request seeks 
information concerning persons, not parties to this litigation, whose privacy rights 
are implicated. 
Request No. 2. 
All documents referring or relating to the United States' 
agreement with Defendant to defer federal prosecution subject to certain 
conditions, including without limitation, the operative agreement between 
Defendant and the United States and all amendments, revisions and 
supplements thereto. 
Response: 
Defendant is asserting specific legal objections to the production 
request as well as his U.S. constitutional privileges. I intend to produce all 
relevant documents regarding this lawsuit, however, my attorneys have 
counseled me that at the present time I cannot select, authenticate, and produce 
documents relevant to this lawsuit and I must accept this advice or risk losing my 
Sixth Amendment right to effective representation. Accordingly, I assert my 
federal constitutional rights under the Fifth, Sixth, and Fourteenth Amendments 
as guaranteed by the United States Constitution. Drawing an adverse inference 
under these circumstances would unconstitutionally burden my exercise of my 
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Jane Doe No. 2 v. Epstein 
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constitutional rights, would be unreasonable, and would therefore violate the 
Constitution. In addition to and without waiving his constitutional privileges, the 
information sought is privileged and confidential, and inadmissible pursuant to 
the terms of the deferred prosecution agreement, Fed. Rule of Evidence 410 and 
408, and §90.410, Fla. Stat. Further, the request is overly broad, work product, 
attorney-client privileged, and confidential. 
In addition, the request seeks 
information concerning persons, not parties to this litigation, whose privacy rights 
are implicated. 
Request No. 3. 
All documents referring or relating to Defendant's agreement 
with the State of Florida on his plea of guilty to violations of Florida Criminal 
Statutes, including without limitation, the operative plea agreement and any 
amendments, revisions and supplements thereto. 
Response: Defendant is asserting specific legal objections to the production 
request as well as his U.S. constitutional privileges. I intend to produce all 
relevant documents regarding this lawsuit, however, my attorneys have 
counseled me that at the present time I cannot select, authenticate, and produce 
documents relevant to this lawsuit and I must accept this advice or risk losing my 
Sixth Amendment right to effective representation. Accordingly, I assert my 
federal constitutional rights under the Fifth, Sixth, and Fourteenth Amendments 
as guaranteed by the United States Constitution. Drawing an adverse inference 
under these circumstances would unconstitutionally burden my exercise of my 
constitutional rights, would be unreasonable, and would therefore violate the 
Constitution. In addition to and without waiving his constitutional privileges, the 
EFTA00067413

Cse 9:08-cv-80119-KAM 
Document 65-4 
Entered on FLSD Docket 03/25/2009 
Page 17 of 37 
Jane Doe No. 2 v. Epstein 
Page 4 
information sought is privileged and confidential, and inadmissible pursuant to 
the terms of the deferred prosecution agreement, Fed. Rule of Evidence 410 and 
408, and §90.410, Fla. Stat. Further, the request is overly broad, work product, 
attorney-client privileged, and confidential. 
In addition, the request seeks 
information concerning persons, not parties to this litigation, whose privacy rights 
are implicated. Whatever public documents exist are in the State Court file and 
equally accessible to Plaintiff. 
Request No.4. 
All documents obtained in discovery or investigation relating 
to either the Florida Criminal Case or the Federal Criminal Case, including 
without limitation, documents obtained from any federal, state, or local law 
enforcement agency, the State Attorney's office and the United States Attorney's 
office. 
Response: Defendant is asserting specific legal objections to the production 
request as well as his U.S. constitutional privileges. I intend to produce all 
relevant documents regarding this lawsuit, however, my attorneys have 
counseled me that at the present time I cannot select, authenticate, and produce 
documents relevant to this lawsuit and I must accept this advice or risk losing my 
Sixth Amendment right to effective representation. Accordingly, I assert my 
federal constitutional rights under the Fifth, Sixth, and Fourteenth Amendments 
as guaranteed by the United States Constitution. Drawing an adverse inference 
under these circumstances would unconstitutionally burden my exercise of my 
constitutional rights, would be unreasonable, and would therefore violate the 
Constitution. In addition to and without waiving his constitutional privileges, the 
EFTA00067414

Case 9:08-cv-80119-KAM 
Document 65-4 
Entered on FLSD Docket 03/25/2009 
Page 18 of 37 
Jane Doe No. 2 v. Epstein 
Page 5 
information sought is privileged and confidential, and inadmissible pursuant to 
the terms of the deferred prosecution agreement, Fed. Rule of Evidence 410 and 
408, and §90.410, Fla. Stat. Further, the request is overly broad, work product, 
attorney-client privileged, and confidential. 
In addition, the request seeks 
information concerning persons, not parties to this litigation, whose privacy rights 
are implicated. Request No. 4 seeks documents that are attorney-client and 
work product privileged in that it seeks "all documents obtained in discovery or 
investigation relating either to the Florida Criminal Case or the Federal Criminal 
Case ... ." In addition, such documents are privileged and confidential as they 
are the subject of a pending investigation. 
Request No. 5. All telephone records and other documents reflecting telephone 
calls made by or to Defendant, including without limitation, telephone logs and 
message pads. 
Response: Defendant is asserting specific legal objections to the production 
request as well as his U.S. constitutional privileges. I intend to produce all 
relevant documents regarding this lawsuit, however, my attorneys have 
counseled me that at the present time I cannot select, authenticate, and produce 
documents relevant to this lawsuit and I must accept this advice or risk losing my 
Sixth Amendment right to effective representation. Accordingly, I assert my 
federal constitutional rights under the Fifth, Sixth, and Fourteenth Amendments 
as guaranteed by the United States Constitution. Drawing an adverse inference 
under these circumstances would unconstitutionally burden my exercise of my 
constitutional rights, would be unreasonable, and would therefore violate the 
EFTA00067415

Case 9:08-cv-80119-KAM 
Document 65-4 
Entered on FLSD Docket 03/25/2009 
Page 19 of 37 
Jane Doe No. 2 v. Epstein 
Page 6 
Constitution. In addition to and without waiving his constitutional privileges, the 
information sought is privileged and confidential, and inadmissible pursuant to 
the terms of the deferred prosecution agreement, Fed. Rule of Evidence 410 and 
408, and §90.410, Fla. Stat. Further, the request is overly broad, work product, 
attorney-client privileged, and confidential. 
In addition, the request seeks 
information concerning persons, not parties to this litigation, whose privacy rights 
are implicated. 
Defendant objects as the request is overbroad and seeks 
information that is neither relevant to the subject matter of the pending action nor 
does it appear reasonably calculated to lead to the discovery of admissible 
evidence. Plaintiff's complaint alleges a time period of "in or about 2004 — 2005." 
Plaintiffs request seeks information for a time period of January 1, 2003 until 
present regarding any and all telephone records and other documents reflecting 
any and all telephone calls made to or by Defendant. As phrased, the request 
includes attorney-client and work product privileged information, as well as 
records and documents of calls having absolutely no relationship to any of the 
allegations in this action. 
Request No. 6. All telephone records and other documents reflecting telephone 
calls made by or to Defendant, including without limitation, telephone logs and 
message pads, reflecting telephone calls made by or to employees. 
Response: Defendant is asserting specific legal objections to the production 
request as well as his U.S. constitutional privileges. I intend to produce all 
relevant documents regarding this lawsuit, however, my attorneys have 
counseled me that at the present time I cannot select, authenticate, and produce 
EFTA00067416

Case 9:08-cv-80119-KAM 
Document 65-4 
Entered on FLSD Docket 03/25/2009 
Page 20 of 37 
Jane Doe No. 2 v. Epstein 
Page 7 
documents relevant to this lawsuit and I must accept this advice or risk losing my 
Sixth Amendment right to effective representation. Accordingly, I assert my 
federal constitutional rights under the Fifth, Sixth, and Fourteenth Amendments 
as guaranteed by the United States Constitution. Drawing an adverse inference 
under these circumstances would unconstitutionally burden my exercise of my 
constitutional rights, would be unreasonable, and would therefore violate the 
Constitution. In addition to and without waiving his constitutional privileges, the 
information sought is privileged and confidential, and inadmissible pursuant to 
the terms of the deferred prosecution agreement, Fed. Rule of Evidence 410 and 
408, and §90.410, Fla. Stat. Further, the request is overly broad, work product, 
attorney-client privileged, and confidential. In addition, as defined by Plaintiff in 
paragraph g of her request, the term employee is overly broad and encompasses 
information that is neither relevant to the subject matter of the pending action nor 
does it appear reasonably calculated to lead to the discovery of admissible 
evidence. Further, the request seeks information pertaining to person who are 
not parties to this action and whose privacy rights are implicated. 
Request No. 7. All surveillance videos, slides, film, videotape, digital recording 
or other audio or video depiction or image of the Palm Beach Residence. 
Response: Defendant is asserting specific legal objections to the production 
request as well as his U.S. constitutional privileges. I intend to produce all 
relevant documents regarding this lawsuit, however, my attorneys have 
counseled me that at the present time I cannot select, authenticate, and produce 
documents relevant to this lawsuit and I must accept this advice or risk losing my 
EFTA00067417